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The following explains the refrigerant gas management program to be included in the AB 32 legislation in California. We will also provide details related AC/HVAC system refrigerant gas leak detection, monitoring, tracking, and reporting. These details related to the California Air Resources Board (CARB) regulation to be passed in early 2009 as well as the anticipated U.S. EPA adoption of similar regulations.
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[ Free Whitepaper ]
Collecting, organizing, and reporting of refrigerant gas data is challenging, the complexity of system auditing is confusing, and it remains difficult to remain in compliance with regulations. Learn how-to survive managing your refrigerants.
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| About The CARB Refrigerant Gas Management Program |
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Refrigerant Tracker from Verisae enables accurate tracking and reporting of refrigerant gas usage across a distributed enterprise. Remain in compliance with Refrigerant Tracker. Know accurate inventories, keep updated maintenance logs, and track usage of refrigerants across all of your locations and AC/HVAC systems.
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Environmental compliance regulations are often misunderstood by owners and operators of facilities who must comply. In regard to refrigerant management, the California Air Resource Board (CARB) and U.S. Environmental Protection Agency (EPA) have drafted the 2009 CARB refrigerant program and the proposed EPA regulation orders for managing High Global Warming Potential (GWP) refrigerants.
The proposed California Air Resource Board (CARB) draft legislation is identified as Subchapter 10, Article X, Sections 9 through 17 with sub-sections included of the California Code of Regulations which was created on September 4, 2008. As of this writing, the CARB early action members are working through a schedule of meetings to collect any feedback and refine the Stationary Equipment Refrigerant Management Program before it becomes law later in 2009.
Understanding refrigerant gas management regulations, including the 2009 CARB program and the expected EPA regulations, one can break down the overall topics into three main areas: * Purpose, * Applicability, and * Definitions.
Purpose of Stationary Equipment Refrigerant Management Program
The purpose of the regulation relates to the management of high global warming potential (GWP) refrigerant. The regulation is intended to reduce emissions of refrigerants from stationary refrigeration systems and air conditioning (AC/HVAC) units. Secondary to reduction of emissions from refrigerants is the requirement for owners and operators of such equipment to institute new methods of reclaiming, recycling or recovering refrigerant as well as to encourage proper repair or replacement of obsolete refrigeration and air conditioning equipment with state-of-the-art (SOTA) equipment.
CARB and many of the leading manufacturers are in discussions to ensure that manufacturer specifications meet the emerging CARB and EPA standards. There is still work to be done especially in the area of cylinder management and the establishment of unique serial numbers for refrigerant gas containers. For pervasive industry wide tracking of refrigerant gases, the establishment of a set of protocols for cylinder identification will continue to be important.
Applicability of AC/HVAC System Monitoring, Tracking, and Registration
These regulations provide a better understanding of who must comply. Essentially, the new CARB refrigerant management program applies to;
A) Any persons who own or operate stationary refrigeration or air conditioning systems containing refrigerant gas, and
B) Any persons who are engaged in installation, repair, maintenance, service, replacement recycling or disposal of stationary refrigeration or air conditioning systems as well as sellers of refrigerant.
Definitions and Key Refrigerant Gas Management Terms
Included in the CARB regulations is a useful guide that explains in detail many of the regulatory terms applicable and in hoping to facilitate enhanced compliance. In this section, refrigerant gases, refrigerant leak, refrigerant usage events are explained in detail so that facility refrigerant management and refrigerant tracking are easily reported. Additional definitions and applicable citations include "Additional Refrigerant Charge", "Air Conditioning System", which defines AC/HVAC equipment as it applies to the regulation, "Air District" which means an Air Quality Management District or Air Pollution Control District for the purpose of refrigerant reporting and submittals, "Air Pollution Control Officer", and a citation for "Automatic Leak Detection" as well as for specification for qualifications on certifications for reclaimers and other certified technicians.
Why Refrigerant System Management is Such a Big Deal
Understanding the CARB Stationary Equipment Refrigerant Management Program regulation is simplified and outlined in their 27-page draft. As mentioned, there will be changes to this refrigeration program. It is known, due to mandatory deadlines for completion of this regulation that it will pass in 2009 and be effective in 2010.
As with all environmental compliance, determining whether an owner or operator must comply is the first step. Using the 2009 CARB draft as a guide, refrigerant management from an enforcement and user standpoint addresses the problem of refrigerant gases that increase global warming effects in a judicious and effective initiative.
Most importantly, the 2009 CARB draft raises awareness of daily refrigerant usage and encourages user implementation of new methods of tracking, maintaining and reporting that collectively reduces harmful emissions into the atmosphere. Such environmental regulations inspire greater environmental safety and responsibility by the user and the obvious benefit to general health and the environment.
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